monterey-salinas transit language assistance...

Monterey-Salinas Transit

LANGUAGE

ASSISTANCE PLAN

EFFECTIVE: JUNE 2017 – JUNE 2020

Monterey-Salinas Transit 19 Upper Ragsdale Dr., Suite 200

Monterey, CA 93940

Title VI Contact: Deanna Smith, Compliance Analyst [email protected]

1-888-678-2871

mailto:[email protected]

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ACKNOWLEDGMENTS

The following individuals assisted with the preparation of this Language Assistance Plan:

Monterey-Salinas Transit:

Deanna Smith, Compliance Analyst/Title VI Coordinator (lead preparer)

Hunter Harvath, Assistant General Manager - Finance & Administration

Michelle Overmeyer, Grants Analyst

Lisa Rheinheimer, Director of Planning and Marketing

Carl Sedoryk, General Manager/CEO

Association of Monterey Bay Area Governments:

Gina Schmidt, GIS Coordinator, AMBAG

Sean Reilly Vienna, Planner, AMBAG

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TABLE OF CONTENTS

ACKNOWLEDGMENTS ................................................................................................................. 2

TABLE OF CONTENTS ................................................................................................................... 3

1. EXECUTIVE SUMMARY ............................................................................................................ 5

2. INTRODUCTION ....................................................................................................................... 7

Service Area Boundaries ....................................................................................................................... 7

Service Area Population ........................................................................................................................ 9

3. FOUR-FACTOR ANALYSIS ...................................................................................................... 11

Factor 1: Identification of LEP Individuals .............................................................................................. 11

American Community Survey Data ..................................................................................................... 11

GIS Analysis of the American Community Survey ............................................................................... 13

California Department of Education Data........................................................................................... 19

Summary ............................................................................................................................................. 20

Factor 2: Frequency of Contact by LEP Persons with MST Services ................................................. 20

Employee Survey ................................................................................................................................. 21

Language Interpretation Data ............................................................................................................. 23

Transit Rider Survey ............................................................................................................................ 24

Summary ............................................................................................................................................. 25

Factor 3: Importance of Programs, Activities, and Services to LEP Persons ................................... 25

Summary ............................................................................................................................................. 27

Factor 4: Resources Available to the Recipient and Costs ................................................................ 28

Current language Assistance Measures and Costs ............................................................................. 28

Language Sssistance Measures June 2017-June 2020 ........................................................................ 28

4. LANGUAGE IMPLEMENTATION PLAN .................................................................................. 31

Element 1: Identifying LEP Individuals who Need Language Assistance ............................................ 31

Element 2: Providing Language Assistance Measures ........................................................................ 31

Element 3: Training Staff ..................................................................................................................... 34

Element 4: Providing Notice to LEP Persons ....................................................................................... 34

Element 5: Monitoring and Updating the Plan ................................................................................... 35

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1. EXECUTIVE SUMMARY

Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et seq., and its implementing regulations provide

that no person in the United States shall, on the grounds of race, color, or national origin, be excluded

from participation in, be denied the benefits of, or otherwise be subjected to discrimination under any

program or activity that receives federal financial assistance.

In compliance with Title VI regulations, including U.S. Department of Justice (DOJ) 28 CFR § 42.401 et

seq., and 28 CFR § 50.3; U.S. Department of Transportation (DOT) 49 CFR part 21; and Executive Order

13166 “Improving Access to Services for Persons with Limited English Proficiency” (2000), MST has

developed this Language Assistance Plan (LAP). Per guidance found in FTA Circular 4702.1B and DOT LEP

Guidance 70 FR 74087, December 14, 2005, MST has taken “reasonable steps to ensure meaningful

access to the benefits, services, information, and other important portions of their programs and

activities for individuals who have limited-English proficiency.” Title VI regulations define limited English

proficient (LEP) individuals as those who speak, read, write, or understand English “less than very well.”

MST supports the goal of Title VI and believes that providing language assistance will have a positive

impact on Monterey County’s LEP population and its ridership in general. This Language Assistance Plan,

effective June 1, 2017 to June 1, 2020, reflects MST’s compliance with federal Title VI regulations and its

continuous efforts to ensure meaningful access to transit services for all persons, regardless of race,

color, or national origin.

Using the four-factor analysis proscribed by USDOT, MST has assessed the language needs within its

service area, which includes the cities of Carmel-by-the-Sea, Del Rey Oaks, Gonzales, Greenfield, King,

Marina, Monterey, Pacific Grove, Salinas, Sand City, Seaside, Soledad, and the County of Monterey.

According to USDOT guidance and Circular 4702.1B Chapter III-7 Section 9(a), the federally-funded

recipient’s obligation to accommodate LEP populations is determined by balancing the following four

factors:

Factor 1: the number or proportion of LEP persons eligible to be served, or likely to be

encountered, by a program, activity, or service

Factor 2: the frequency with which LEP individuals come in contact with the program, activity, or

service

Factor 3: the nature and importance of the program, activity, or service to people’s lives

Factor 4: the resources available to the recipient

To address Factor One, MST incorporated the most recently available data from the 2011-2015 U.S.

Census American Community Survey (ACS) and the California Department of Education (CDE), which

identified four LEP language groups within the its service area that meet the DOJ’s Safe Harbor threshold

of “five percent or 1,000 persons, whichever is less, of the total population of persons eligible to be

served or likely to be affected or encountered” by MST. These languages include Spanish, Tagalog,

Vietnamese, and Korean. This is the first time MST has identified an LEP language group other than

Spanish meeting this threshold.

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To address factors two and three, MST reviewed employee survey responses, tracked the language

assistance activity provided by MST’s language interpretation provider, and analyzed responses from its

most recent 2016 Onboard Rider Survey to determine the frequency with which LEP individuals come in

contact with its programs, activities, or services, and how important these programs, activities, or

services are to their daily lives.

After assessing the first three factors, MST weighed the demand for language assistance against its

current financial and personnel resources and developed a language assistance implementation plan

that includes the following four elements:

1. Identifying LEP individuals who need language assistance

2. Providing language assistance

3. Training MST staff

4. Providing notice to LEP customers

5. Monitoring and updating the LAP

With the addition of two new LEP language groups during this June 2017-June 2020 Title VI Program

update, this Language Assistance Plan will be a valuable resource to MST employees who work daily to

provide Monterey County residents and visitors meaningful access to public transportation and will help

ensure these benefits, services, and information are equally shared by those with limited-English

proficiency. A copy of all census data used to complete the Four Factor Analysis can be found in

Attachment J of MST’s Title VI Program update.

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2. INTRODUCTION

In 2009, Monterey-Salinas Transit sponsored legislation (AB 644 Caballero) creating the Monterey-

Salinas Transit District under Public Utilities Code Section 106000, effective July 1, 2010.

Each of the 12 cities within Monterey County and the County of Monterey appoints an elected official

from their governing council or board to serve on the MST Board of Directors (Board). The following

jurisdictions are represented on the MST Board:

The City of Carmel-by-the-Sea

The City of Del Rey Oaks

The City of Gonzales

The City of Greenfield

The City of King

The City of Marina

The City of Monterey

The City of Pacific Grove

The County of Monterey

The City of Salinas

The City of Sand City

The City of Seaside

The City of Soledad

In 2016, MST’s fixed route fleet of 123 buses, shuttles, and trolleys boarded 4.3 million passengers,

while the MST RIDES paratransit service carried 114,829 passengers with a fleet of 29 vehicles.

MST currently employs 241 individuals including 133 coach operators; 77 operations, maintenance and

facilities workers; and 31 administrative staff1 who operate out of the following locations:

Clarence J. Wright Operations Division – Salinas

Frank J. Lichtanski Administration Building – Monterey

Joe Lloyd Way Temporary Maintenance & Operations Facility – Seaside

Thomas D. Albert Maintenance & Operations Facility – Monterey

Bus Stop Shop – Monterey

Mobility Management Center – Monterey

Salinas Transit Center

Sand City Station

Marina Transit Exchange

Monterey Transit Plaza

SERVICE AREA BOUNDARIES

MST provides public transportation to an approximate 294 square-mile area of Monterey County,

Southern Santa Cruz County, Northern San Luis Obispo County, and Santa Clara County. Although MST

provides service connections within these neighboring counties, its official jurisdictional boundary – as

defined within its enabling legislation AB 644 – is confined to the 12 cities and unincorporated areas of

Monterey County2 (Figure 1). For the purposes of this Language Assistance Plan, population and other

statistical data used to determine limited English proficiency have been limited to its official

jurisdictional boundaries.

1 Total staffing levels as of February 28, 2017.

2 AB 644 (106010) states: “There is hereby created the Monterey-Salinas Transit District. The jurisdiction of the

district extends throughout the county, including all of the incorporated and unincorporated territory.”

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Figure 1: MST Regional Map

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SERVICE AREA POPULATION

MST is accountable to a diverse population of individuals who reside, work, and travel within Monterey

County. American Community Survey 2011-2015 5-Yr. data estimates Monterey County’s population of

428,441 to be 51.2 percent male and 48.8 percent female, with a median age of 33.5 years3 (Table 1).

Table 1: Monterey County Population Estimates by Sex and Age

Subject Monterey County

2011-2015

Sex/Age

Total Population 428,441

Male 51.2%

Female 48.8%

Median Age 33.5

18 years and over 73.5%

Male 51.2%

Female 48.8%




Male 44.7%

Female 55.3%

ACS data also estimates that 56.9 percent of Monterey County’s population is Hispanic or Latino, 31.5

percent white, and 5.9 percent Asian (Table 2).

Table 2: Monterey County Population Estimates by Race and Ethnicity

Subject Monterey County

2011-2015

Race/Ethnicity

Total Population 428,441

Hispanic or Latino (of any race) 56.9%

White 31.5%

Asian alone 5.9%

Black or African American alone 2.6%

Two or More Races 2.3%

Native Hawaiian and Other Pacific Islander .5%

American Indian and Alaska Native .3%

To determine MST’s obligation to accommodate LEP populations within its service area, the following

FTA recommended four-factor analysis was conducted and is detailed in the following chapter.

3 Source: ACS 2011-2015 5-Yr. Estimate, Table CP05, Comparative Demographic Estimates.

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3. FOUR-FACTOR ANALYSIS

The Safe Harbor provision of FTA Circular 4702.1B stipulates that, “if a recipient provides written

translation of vital documents for each eligible LEP language group that constitutes five percent or 1,000

persons, whichever is less, of the total population of persons eligible to be served or likely to be affected

or encountered, such action will be considered strong evidence of compliance with the recipient’s

written translation obligations.”

MST has identified four LEP populations of 1,000 or more individuals who speak English “less than very

well” and for whom notice of language assistance and written translation of vital documents is required:

Spanish, Tagalog, Vietnamese, and Korean.

According to USDOT guidance, the federally-funded recipient’s obligation to accommodate LEP

populations is determined by balancing four factors:

Factor 1: the number or proportion of LEP persons eligible to be served, or likely to be

encountered, by a program, activity, or service

Factor 2: the frequency with which LEP individuals come in contact with the program, activity, or

service

Factor 3: the nature and importance of the program, activity, or service to people’s lives

Factor 4: the resources available to the recipient

FACTOR 1: IDENTIFICATION OF LEP INDIVIDUALS

“The greater the number or proportion of LEP individuals from a particular language group served or

encountered in the eligible service population, the more likely language services are needed…” (DOT LEP

Guidance Section V (1)).

AMERICAN COMMUNITY SURVEY DATA

For Factor One, MST analyzed census data from the American Community Survey 2011-2015 5-year

sample4 to determine the number or proportion of LEP persons eligible to be served or likely to be

encountered by a program, activity, or service provided by MST. ACS census data estimate that of the

total population in the MST service area aged five years and over who speaks a language other than

English, 113,939 individuals speak English less than very well. This number represents MST’s LEP

population and is 28.8 percent of the total MST service area population of 395,093.

The most prevalent non-English language spoken in the MST service area is Spanish (103,580 LEP

persons), and these LEP speakers account for 26.2 percent of the total population within this service

area. Tagalog LEP speakers (2,201 LEP persons) account for .5 percent of MST’s total population. Two

additional languages meet the threshold of FTA’s Safe Harbor provision: Vietnamese (1,303 LEP

4 Source: ACS 2011-2015 5-Yr. Estimate, Table B16001Language Spoken at Home by Ability to Speak English for the

Population 5 Years and Over.

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persons), and Korean (1,176 LEP persons). These four language groups represent MST’s Safe Harbor

languages (Table 3).

Table 3: Monterey County LEP Estimates for the Population 5 Years and Over

ACS LEP Population (speaks English less

than very well)

% of Total Population

% of Total LEP Population

Total Population ACS 2011-2015 395,093 113,939 28.84%

Spanish or Spanish Creole 103,580 26.22% 90.91%

Tagalog 2,201 0.56% 1.93%

Vietnamese 1,303 0.33% 1.14%

Korean 1,176 0.30% 1.03%

Chinese 851 0.22% 0.75%

Arabic 685 0.17% 0.60%

Japanese 627 0.16% 0.55%

Other and Unspecified Languages 572 0.14% 0.50%

Other Pacific Island Languages 430 0.11% 0.38%

Italian 306 0.08% 0.27%

Other Indic Languages 230 0.06% 0.20%

Portuguese 220 0.06% 0.19%

Russian 205 0.05% 0.18%

German 170 0.04% 0.15%

Mon-Khmer, Cambodian 157 0.04% 0.14%

Persian 149 0.04% 0.13%

Hindi 145 0.04% 0.13%

Other Asian Languages 125 0.03% 0.11%

Other Indo-European Languages 122 0.03% 0.11%

Thai 111 0.03% 0.10%

Other Slavic Languages 110 0.03% 0.10%

Gujarati 107 0.03% 0.09%

Hmong 94 0.02% 0.08%

French 90 0.02% 0.08%

Armenian 36 0.01% 0.03%

Urdu 35 0.01% 0.03%

Other West Germanic Languages 26 0.01% 0.02%

African Languages 22 0.01% 0.02%

Serbo-Croatian 18 0.00% 0.02%

Scandinavian Languages 16 0.00% 0.01%

Greek 8 0.00% 0.01%

Hebrew 8 0.00% 0.01%

Polish 4 0.00% 0.00%

Total LEP 113,939 28.84% 100.00%

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Using ACS data, MST’s four LEP language groups were identified by their estimated populations within

each of Monterey County’s cities (Table 4). This information will assist MST in identifying concentrations

of specific language groups within its service area and providing appropriate language assistance for

public hearings, meetings, written materials, and other outreach efforts.

Table 4: Monterey County LEP Population by City

Geography Spanish Tagalog Vietnamese Korean Total LEP Population

Carmel-by-the-Sea 26 0 0 0 26

Del Rey Oaks 40 10 4 0 54

Gonzales 2,922 0 0 0 2,922

Greenfield 6,963 0 0 0 6,963

King City 6,731 0 0 15 6,746

Marina 1,888 319 545 407 3,159

Monterey 1,193 20 0 118 1,331

Pacific Grove 165 27 20 92 304

Salinas 52,524 987 514 271 54,296

Sand City 49 0 0 0 49

Seaside 6,219 406 181 166 6,972

Soledad 6,923 73 14 11 7,021

Total Monterey County by Incorporated Cities 85,643 1,842 1,278 1,080 89,843

GIS ANALYSIS OF THE AMERICAN COMMUNITY SURVEY

All data sources used to determine the number or proportion of LEP persons eligible to be served, or

likely to be encountered by a program, activity, or service provided by MST confirm that Spanish is the

primary LEP language group in Monterey County, representing 26.2 percent of its total population of

395,093 and 90.9 percent of its total LEP population of 113,939. The additional three LEP populations

identified during this Title VI Program Update cycle – Tagalog, Vietnamese, and Korean – together

represent just over 4 percent of Monterey County’s total population and 1.2 percent of its total LEP

population.

The City of Salinas has the highest number of Spanish LEP individuals, with a primary concentration

occurring along the Salinas Valley corridor. Tagalog, Vietnamese, and Korean LEP populations cluster

primarily in the cities of Salinas, as well as Marina and Seaside on the Monterey Peninsula.

To provide a geographic picture of where concentrations of LEP individuals live within MST’s service

area, LEP populations were identified by census tract and are represented in the following series of

maps. Figure 2 identifies the total LEP population concentration by census tract as a percentage of

Monterey County’s total population, and Figures 3-6 identify each of the four LEP language groups

individually by census tract as a percentage of Monterey County’s total population.

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Figure 2: Composition of LEP Population by Census Tract in Monterey County

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Figure 3: LEP Population that speak Spanish by Census Tract

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Figure 4: LEP Population that speak Tagalog by Census Tract

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Figure 5: LEP Population that speak Vietnamese by Census Tract

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Figure 6: LEP Population that speak Korean by Census Tract

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CALIFORNIA DEPARTMENT OF EDUCATION DATA

FTA guidelines recommend that alternate and local sources of data are analyzed when conducting a

four-factor analysis. MST reviewed data from the California Department of Education (CDE) to identify

the number of English-learner students5 enrolled in Monterey County’s 24 school districts6. Of

Monterey County’s total school population, 31,165 students are English learners (Table 5).

Table 5: Total Monterey County 2015-2016 English Learner Enrollment

Total Monterey County Area School Population 76,768

Total area English learner population 31,165 (40.6% of total school population)

Number of languages reported spoken by the area’s English learner population 54

MST also reviewed 2015-2016 CDE enrollment data which broke down the total number of English

learner students by their primary language7 (Table 6). Although Mixteco and Arabic are identified

among the top six English learner languages, Arabic did not meet the FTA Safe Harbor threshold of five

percent or 1,000 persons within MST’s service area.

It should be noted that Mixteco is a group of as many as 50 Oto-Manguean languages spoken by people

in the Mexican states of Oaxaca, Pueblo, and Guerrero, as well as other areas in California and the

United States8. A small population of Triqui speakers resides within the MST service area, particularly in

Southern Monterey County, although accurate numbers are not available. Because the majority of local

Triqui speakers prefer verbal interpretation to written translation, Triqui will be considered as a

language group within Monterey County’s Spanish-speaking LEP population. Efforts to engage and

provide language assistance to this population will be discussed later in this document.

Table 6: English Learner Students by Language

Language Kinder – Grade 12 Ungraded Total English Learners

Percent of Total English Learners

Spanish 29,417 36 29,453 94.51%

Mixteco 308 0 308 .99%

Arabic 205 0 205 .66%

Tagalog 200 0 200 .64%

Vietnamese 80 0 80 .26%

Korean 54 0 54 .17%

All other languages 865 0 865 2.77%

Total 31,129 36 31,165 100%

5 The California Department of Education defines English-learner students as those who do not speak, read, write,

or understand English well as a result of English not being their home language. 6 Source: CDE 2015-2016 Monterey County Language Group Data – Countywide.

7 Source: CDE 2015-2016 English Learner Students by Language by Grade – Monterey County.

8 Source: http://www.omniglot.com/writing/mixtec.htm

http://www.omniglot.com/writing/mixtec.htm

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SUMMARY

MST began the Factor One assessment by reviewing the most recent U.S. Census American Community

Survey data. The results of this assessment confirmed that Spanish, Tagalog, Vietnamese, and Korean

meet FTA’s Safe Harbor threshold of five percent or 1,000 persons of the total population of persons

eligible to be served or likely to be affected or encountered within MST’s service area.

To provide a geographic picture of where concentrations of LEP individuals live within MST’s service

area, LEP populations were identified by census-tract and represented in a series of GIS maps. LEP

population concentrations were mapped as a percentage of Monterey County’s total population, and

each of the four LEP language groups meeting FTA’s Safe Harbor threshold were mapped individually by

census tract as a percentage of Monterey County’s total population.

Finally, data from the California Department of Education identified Monterey County’s school

population of English learners, which, with the exception of Arabic and Mixteco, aligned with ACS data.

Since Arabic met neither the five percent nor the 1,000 person threshold, it will not be included as one

of MST’s Safe Harbor language groups. Mixteco represents a large group of indigenous languages of

Mexico, one of which is Triqui, a language group that is present in Monterey County although not

identified individually within census data. Triqui, therefore, will be addressed specifically within MST’s

Language Assistance Plan as part of the Spanish LEP language group later in this document.

Given the substantially higher population of LEP Spanish speakers within MST’s service area and the

relatively low population of Tagalog, Vietnamese, and Korean LEP speakers, MST has created two

categories to classify its LEP language groups for the purpose of developing this Language Assistance

Plan: Primary and Secondary (Table 7). This LEP classification will be used to determine the level of

language assistance MST will implement as a result of this Language Assistance Plan.

Table 7: MST LEP Language Groups

Category Language

PRIMARY Spanish

SECONDARY Tagalog, Vietnamese, Korean

FACTOR 2: FREQUENCY OF CONTACT BY LEP PERSONS WITH MST SERVICES

“Recipients should assess, as accurately as possible, the frequency with which they have or should have

contact with LEP individuals from different language groups seeking assistance, as the more frequent the

contact, the more likely enhanced language services will be needed.” (DOT LEP Guidance Section V (2))

MST used three sources to determine how frequently LEP individuals use MST services and how often

MST staff comes in contact with or assists LEP individuals:

1. MST employee survey

2. Language interpretation and translation data

3. MST onboard rider survey

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0%

17%

11%

72%

Never

1 to 5

6 to 10

10 or More

EMPLOYEE SURVEY

Because MST’s customer service representatives, coach operators, operations supervisors, and mobility

staff most frequently interact directly with the public, they were surveyed on the frequency with which

they have come in contact with or assisted LEP customers (Table 8). Survey response rates for the four

groups of employees were as follows:

Table 8: Employee Survey Response Rate

Group Staffing Level

Respondents Response Rate

Customer Service Representatives 5 5 100%

Coach Operators 138 52 37%

Operations Supervisors 9 4 44%

Mobility Staff 6 3 50%

Total 152 64 42%

Question 1: How many times in the past year have you encountered a customer who could not speak

English?

Approximately two-thirds of respondents have encountered ten or more non-English speaking

customers over the past year (Figure 7). All employees reported encountering a non-English speaking

customer at least 1-5 times in the past year.

Figure 7: Employee Interaction with Non-English Speakers in Previous Year

Question 2: How many times in the past year have you encountered a customer who spoke the

following languages?

About eight in ten respondents have encountered a customer who spoke Spanish more than ten times

in the past year (Figure 8). This high rate of interaction with Spanish-speakers correlates with ACS and

other census LEP population data. Employees reported encountering customers speaking Tagalog,

Vietnamese, or Korean at much lower frequencies than those who speak Spanish.

Coach Operators

Never 1 to 5 6 to 10 10 or More

0 7 7 38

Operations Supervisors


0 2 0 2

Customer Service Representatives


0 0 0 5

Mobility Staff


0 2 0 1

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14%

5%

81%

Spanish


39%

34%

13%

14%

Tagalog


56% 28%

8% 8%

Vietnamese


66% 19%

8% 8%

Korean


Figure 8: Employee interaction with MST Limited English Populations in Previous Year

All Respondents


Spanish 0 9 3 52

Tagalog 25 22 8 9

Vietnamese 36 18 5 5

Korean 42 12 5 5

Question 3: How many times in the past year have you provided/obtained language assistance for a

customer who spoke the following languages?

MST contracts with Language Line Solutions9 to provide telephone or in-person interpretation and

translation assistance in over 240 languages. MST customer service representatives, operations

supervisors, and mobility management staff are trained to access this service directly, and coach

9 Language Line Solutions, based in Monterey, CA, provides phone, video, and onsite interpreting, translation and

localization, and interpreter training services, using highly trained and professional linguists. https://www.languageline.com/

https://www.languageline.com/

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11%

19%

14%

56%

Spanish


69%

27%

3% 2%

Tagalog


78%

19%

2% 2%

Vietnamese


83%

13%

2% 3%

Korean


operators are instructed in how to interact with LEP customers. Additionally, all of MST’s customer

service representatives speak Spanish.

Over half of all survey respondents have provided or obtained language assistance for a Spanish-

speaking customer. Only about 5 percent of employees have provided or obtained language assistance

for customers speaking Tagalog, Vietnamese, or Korean more than six times in the past year (Figure 9).

Figure 9: Language Assistance provided to MST Limited English Populations in Previous Year

All Respondents


Spanish 7 12 9 36

Tagalog 44 17 2 1

Vietnamese 50 12 1 1

Korean 53 8 1 2

LANGUAGE INTERPRETATION DATA

MST evaluated its language interpretation/translation service data to determine the number of LEP

individuals for whom language assistance was provided over an 18-month period (Figure 10). From

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75.0%

8.3%

8.3%

8.3%

Spanish

Pashto

Mandarin

Farsi

August 1, 2015, through January 31, 2017, 12 customers accessed language interpretation services over

the telephone. Of these, nine spoke Spanish, one spoke Pashto, one spoke Mandarin, and one spoke

Farsi. Language assistance was not requested by LEP customers speaking Tagalog, Vietnamese, or

Korean.

Figure 10: Interpretation Services Provided by Language 8/1/2016-1/31/2017

TRANSIT RIDER SURVEY

In 2016, MST hired consultants to conduct a transit rider survey designed to quantify usage, measure

satisfaction levels, track travel behavior, and identify service perceptions. The objectives of the onboard

survey were to gain insight into MST customers’ opinions spanning across many regular MST service

lines, and to compile a demographic profile of the typical MST rider10. The resulting profile rider is an

English-speaking male, age 18-24, employed, with an annual household income of less than $10,000.

Nearly half of all survey respondents reported riding the bus five or more times per week (Figure 11).

Figure 11: Survey Response: Ridership per Week, Per Individual

10

A total of 600 valid surveys were collected, exceeding the sample target of 375.

Language Interpretation Services

Total Minutes

Total Calls

Avg. Call Length

Spanish 54 9 6

Pashto 28 1 28

Mandarin 8 1 8

Farsi 3 1 3

93 12 45

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Survey respondents overwhelmingly reported that English is the primary language spoken at home (70.7

percent). While 26.3 percent reported speaking Spanish at home, all other languages represented only 3

percent of survey respondents (Figure 12). The survey was provided in English and Spanish only;

therefore, reliable survey data for LEP riders speaking Tagalog, Vietnamese, and Korean cannot be

guaranteed. Given that these three language groups have been identified as meeting FTA’s Safe Harbor

threshold, it is recommended in Chapter 4 that future Onboard Rider Surveys be provided in each of

these languages.

Figure 12: Survey Response: Primary Language Spoken at Home

SUMMARY

While MST used external census data to determine the number or proportion of LEP persons eligible or

likely to be served or encountered by MST in the provision of transit services, both external and internal

resources were used to determine how frequently LEP individuals use MST services and how often MST

staff comes in contact with or assists persons with limited English proficiency. All three data sources

confirmed that MST staff most often come in contact with and assist Spanish-speaking LEP individuals.

Although data from the Onboard Rider Survey confirmed that English is the primary language spoken at

home, all other data reviewed by MST confirm that its primary LEP language group is Spanish. Tagalog

was the only one of MST’s LEP language groups specifically identified in Figure 12 as a primary language

spoken at home; therefore, its classification as MST’s secondary LEP language group is supported by all

three data sources.

FACTOR 3: IMPORTANCE OF PROGRAMS, ACTIVITIES, AND SERVICES TO LEP PERSONS

“The more important the activity, information, service, or program, or the greater the possible

consequences of the contact to the LEP individuals, the more likely language services are needed...A

recipient needs to determine whether denial or delay of access to services or information could have

serious or even life-threatening implications for the LEP individual.” (DOT LEP Guidance Section V (3))

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To analyze the importance of MST’s services to LEP riders, MST again reviewed its 2016 Onboard Rider

Survey to complete the following Factor Three analysis. As shown by Figure 11 in the Factor Two

analysis, nearly half of all survey respondents reported riding the bus five or more times per week. MST

riders are not generally choice riders, but are overwhelmingly transit-dependent, citing a lack of

personal vehicle as their primary reason for riding the bus (Figure 13).

Figure 13: Survey Response: Which of the following would you cite as reasons you use MST?

The typical MST rider relies on public transportation to get to work and/or job training, school,

shopping, or to access healthcare services. For this rider, the ability to access public transportation is a

vital necessity. Fewer than 15 percent of riders rely on MST for recreational or other purposes (Figure

14). Additionally, over 78 percent of survey respondents stated that the services MST provides are a

benefit to the community, and nearly 75 percent replied that public transportation saves them or their

family money (Figure 15).

Figure 14: Survey Response: Reason for Using MST Service

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Figure 15: Survey Response: Does public transit saves you and your family money?

SUMMARY

At this point in the Four Factor Analysis, factors one, two, and three have confirmed that:

The most prevalent non-English language spoken in the MST service area is Spanish, accounting

for 26.2 percent of MST’s total population;

Tagalog, Vietnamese, and Korean LEP speakers together represent less that 1.6 percent of MST’s

total service area population, although all three individually meet the 1,000 person FTA Safe

Harbor threshold;

All four of MST’s LEP language groups are represented in the top six English-learner students in

Monterey County schools;

All MST employee survey respondents have encountered a non-English speaking customer at

least 1-5 times in the past year;

Over half of all survey respondents have provided or obtained language assistance for a Spanish-

speaking customer in the past year;

Language assistance was not requested by LEP customers speaking Tagalog, Vietnamese, or

Korean in the past year;

Over 78 percent of MST riders believe transit service is a benefit to the community; and

Nearly 75 percent of MST riders state that transit service saves them money.

It can be concluded that MST’s primary LEP language group is Spanish. While the number of Tagalog,

Vietnamese, and Korean LEP individuals meets the FTA Safe Harbor threshold within Monterey County,

these LEP populations nevertheless represent a small percentage of MST’s total service area population.

To this end, MST has created two categories to classify its LEP language groups for the purpose of

developing this Language Assistance Plan: Primary (Spanish), and Secondary (Tagalog, Vietnamese, and

Korean).

The final step of the required Four Factor analysis will discuss the resources available to develop a

language implementation plan to ensure meaningful access for LEP individuals.

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FACTOR 4: RESOURCES AVAILABLE TO THE RECIPIENT AND COSTS

“A recipient’s level of resources and the costs imposed may have an impact on the nature of the steps it

should take in providing meaningful access for LEP persons.” (DOT LEP Guidance Section V (4))

Factor Four is designed to weigh the demand for language assistance against current and projected

financial and personnel resources. According to the Department of Transportation, “Smaller recipients

with more limited budgets are not expected to provide the same level of language services as larger

recipients with larger budgets. In addition, ‘reasonable steps’ may cease to be reasonable where the

costs imposed substantially exceed the benefits.” USDOT has advised recipients to carefully explore the

most cost-effective means of delivering “competent and accurate” language services to address

resource concerns.

CURRENT LANGUAGE ASSISTANCE MEASURES AND COSTS

MST currently provides a wide range of information and services in Spanish.

All MST Customer Service Representatives are bilingual in English and Spanish.

At least one Spanish interpreter is present at all public meetings.

Public Hearings are noticed in English and Spanish.

Public Hearing materials are provided in English and Spanish.

Telephone interpretation and translation is available through Language Line Solutions in over

240 languages.

MST’s website utilizes Google Translate, providing translation in nearly 100 languages.

MST’s vital documents are available in Spanish on the MST website and by request.

Nearly all of MST’s printed materials, including Rider’s Guide and brochures are available in

English and Spanish.

Informational transit-related signage on buses is in English and Spanish.

Current annual costs associated with providing language assistance and translation for Spanish-speakers

is estimated to be between $20,000 and $28,000. Given the percentage of Spanish-speaking LEP

individuals in MST’s service area, and their reliance on MST’s transit service, it is fitting that MST

continues to provide enhanced written translation and verbal interpretation services to this population.

LANGUAGE ASSISTANCE MEASURES JUNE 2017-JUNE 2020

Currently, most of the costs associated with providing Spanish-language translation and interpretation

services are provided by MST’s bilingual customer service representatives. A base monthly fee is paid to

Language Line Solutions, with additional charges applied for services that exceed the contractual base

rate.

The cost of designing and printing MST’s Rider’s Guide and other support materials are not currently a

line item in MST’s annual budget. With the addition of three LEP Safe Harbor languages, MST will track

these costs beginning with its July 2018 fiscal year budget so that expenses directly related to

implementing Title VI language assistance are accurately tracked.

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Using MST’s LEP language classification (Table 7), Chapter 4 of this document outlines MST’s Language

Implementation Plan which is intended to support MST staff in complying with Title VI regulations.

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4. LANGUAGE IMPLEMENTATION PLAN

Department of Transportation LEP guidance notes that effective language implementation plans

typically include the following five elements: 1) identifying LEP individuals who need language

assistance; 2) providing language assistance measures; 3) training staff; 4) providing notice to LEP

persons; and 5) monitoring and updating the plan.

ELEMENT 1: IDENTIFYING LEP INDIVIDUALS WHO NEED LANGUAGE ASSISTANCE

As discussed in the Four Factor Analysis, MST reviewed a number of sources to identify its LEP

populations. Four LEP language groups met the Safe Harbor threshold of five percent or 1,000 persons,

whichever is less, of the total population of persons eligible to be served or likely to be affected or

encountered within MST’s service area.

Given the substantially higher population of LEP Spanish speakers within MST’s service area and the

relatively low population of Tagalog, Vietnamese, and Korean LEP speakers, MST has created two

categories to classify its LEP language groups: Primary and Secondary. This LEP classification will be used

to determine the level of language assistance MST will implement for each Safe Harbor language:

Category Language

PRIMARY Spanish

SECONDARY Tagalog, Vietnamese, Korean

ELEMENT 2: PROVIDING LANGUAGE ASSISTANCE MEASURES

This is the first Title VI Program Update cycle during which a language other than Spanish has met the

FTA Safe Harbor threshold. To meet the additional language assistance requirements necessary to

support these additional languages, MST has developed new language assistance measures that will be

implemented as outlined below.

As discussed on page 19 of this Language Assistance Plan, Mixteco represents a large group of

indigenous languages of Mexico, one of which is Triqui, a language group that is present in Monterey

County although not identified individually within census data. In the past, MST has provided

professional interpreters at public hearings and other public meetings held in areas that have been

known to have a high concentration of populations who speak this language. Local Triqui speakers and

interpreters have confirmed that most local Triqui populations prefer verbal interpretation to written

translation. MST will continue to provide assistance to this LEP language group as determined by the

location of public meetings and the populations who would likely be affected by fare increases, service

changes, reductions, or losses, as well as other major transportation projects that may require public

hearings. Triqui speakers who request language assistance will be provided appropriate assistance free

of charge, in keeping with MST’s other four LEP populations.

Vital Documents

MST is required to provide written translation of its vital documents into all of its Safe Harbor languages.

According to FTA Circular 4702.1B Chapter III-9, “vital written documents include, but are not limited to,

consent and complaint forms; intake and application forms with the potential for important

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consequences; written notices of rights; notices of denials, losses, or decreased in benefits or services;

and notices advising LEP individuals of free language assistance services.”

MST has created three tiers to classify its written translation efforts: 1) Tier One – to include vital

documents; 2) Tier Two – to include supporting documents; and 3) Tier Three – to include proposed

supporting documents that will be implemented as needed and/or as financial resources allow.

Table 9: Tier One Vital Documents

TIER ONE VITAL DOCUMENTS

Document Language Group

Civil Rights Complaint Forms/Processes & Determination Letters All

Reasonable Modification Request Form & Determination Letters All

Paratransit Applications All

Title VI Notice of Rights All

Notice of Public Hearings – Fares/Service Changes/Major Projects11 All

Notice of Language Assistance All

MST will translate its civil rights (ADA, Title VI) complaint and reasonable modification forms and

processes into all of its Safe Harbor languages. The forms will be available on the MST website in PDF

format or can be filled out directly online using Google Translate. Determination letters will be

translated into the Safe Harbor language that corresponds with the submitted complaint form. MST will

also translate its MST RIDES/paratransit applications into all of its Safe Harbor languages. Language

assistance will be provided through Language Line Solutions or other professional translators, as needed

or requested, for in-person meetings during the application process.

Copies of MST’s English-language Title VI and ADA complaint forms and processes, reasonable

modification request form and process, and MST RIDES paratransit application in English can be found in

Attachment E of MST’s Title VI Program.

MST’s Title VI Notice of Rights will be translated into all Safe Harbor languages and will be posted at all

customer service windows, on MST buses, and at all public meeting locations. The notice will also be

posted on the MST website and will include MST’s Notice of Language Assistance. A copy of MST’s

Notice of Rights can be found in Attachment C of MST’s Title VI Program.

MST currently posts its public hearing notices for fare increases, service changes, reductions, or losses,

and other major projects in English and Spanish. Beginning June 1, 2017, MST will add its Notice of

Language Assistance to all public hearing notices and will translate the notices in all of its Safe Harbor

languages based on the affected area or population. All requests for language assistance will be free of

charge to individuals speaking one of MST’s Safe Harbor languages, although MST will make every effort

to affordably accommodate LEP persons who speak other languages.

MST has created a Notice of Language Assistance to alert the public of this service (Figure 16).

11

MST has defined its threshold for a major service change within its Public Hearing Policy (Attachment C of its Public Participation Plan).

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Figure 16: Notice of Language Assistance - Option 1 and 2

If information is needed in another language, contact 888-678-2871

Si necesita información en otro idioma, llame a 888-678-2871

Kung kailangan ang impormasyon sa ibang wika, makipag-ugnayan sa 888-678-2871

Nếu quý vị cần thông tin bằng một ngôn ngữ khác, vui lòng gọi số 888-678-2871

다른 언어로 된 정보가 필요하실 경우, 888-678-2871 번으로 전화해 주십시오

888-678-2871 / Free language assistance / Asistencia de Lenguaje Gratuito / Libreng tulong

para sa wika / Hỗ trợ ngôn ngữ miễn phí / 무료 언어 지원

Table 10: Tier Two Supporting Documents

TIER 2 SUPPORTING DOCUMENTS


Fare Structure Primary

Taxi Voucher Program Primary

Onboard Fare/Service Change Information12 Primary & Secondary

Onboard Notice of Security Cameras Primary

Paratransit/Travel Training Information Primary

Onboard Safety & Security Information Primary, with use of Symbols/Pictographs when possible.

Public Hearing Materials/Presentations Primary. Secondary as determined by location or as requested.

Construction/Other Courtesy Notices Primary. Secondary as determined by location.

MST will continue to provide its supporting documents in both English and Spanish. As resources allow,

onboard safety and security information will be updated to integrate symbols and pictographs. MST will

also monitor other written information that could be improved by the use of symbols and pictographs.

Public Hearing materials/presentations and construction or other courtesy notices will be provided in

English and Spanish. These materials will be provided in Tagalog, Vietnamese, and Korean as determined

by affected locations or as requested. MST will provide written and/or verbal translation of all

supporting documents in Tagalog, Vietnamese, or Korean upon request or as financial resources allow.

In certain circumstances, MST may opt to provide verbal translation or a written summary, such as

bullet points or highlights, of certain documents in lieu of a full translation.

Table 11: Tier Three Proposed Documents

TIER 3 PROPOSED DOCUMENTS


Civil Rights Brochure Primary & Secondary

Onboard Safe Riding/How to Ride Pamphlet Primary & Secondary

General Promotional Materials (Brochures, pamphlets, etc.) Primary. Secondary as resources allow.

12

MST has defined its threshold for a major service change within its Public Hearing Policy (Appendix C of its Public Participation Plan).

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As resources allow, MST will develop a civil rights brochure to include both Title VI and ADA Notice of

Rights, including information on language assistance resources, procedures and contact information for

filing a complaint, and reasonable modification information in all Safe Harbor language groups. These

brochures will be available onboard MST buses and at all customer service locations. MST will also

consider developing an Onboard Safe Riding/How to Ride pamphlet in all Safe Harbor language groups

as resources allow. Both the civil rights brochure and the safe riding/how to ride pamphlet would

supplement information currently within its Rider’s Guide.

MST currently prints a variety of promotional brochures that highlight local tourist attractions such as

the historic area of Old Monterey, the rugged coastline of Big Sur, and Monterey County’s wineries via

MST’s Grapevine Express. Since these brochures are not vital to fully accessing MST’s transit services,

they will be printed or translated as resources allow. Written translation of the current brochures will

incur a translation fee. It should be noted that MST Rider’s Guide is currently printed in English and

Spanish. Most pages of the Rider’s Guide are currently available on the MST website and can be

translated into nearly 100 languages with Google Transit.

ELEMENT 3: TRAINING STAFF

MST currently informs all newly-hired employees of Title VI regulations and their responsibility to assist

LEP customers in obtaining language assistance. Tailored training modules have been created for

customer service representatives, operations supervisors, coach operators, and mobility management

staff, with each module designed to highlight the specific obligations and level of interaction each job

group may face.

Coach operators and operations supervisors receive regular Title VI refresher training throughout the

year. Customer service representatives periodically receive updated training on accessing language

assistance through Language Line Solutions. All of these employees are provided support materials such

as language identification cards and instructions on accessing language assistance directly.

With the June 1, 2017 implementation of MST’s Title VI Program update and Language Assistance Plan,

information on MST’s new Safe Harbor language groups and new language assistance measures will be

provided to MST employees.

ELEMENT 4: PROVIDING NOTICE TO LEP PERSONS

MST will use a variety of methods to ensure LEP persons are aware of existing and new language

assistance measures by:

Including MST’s Notice of Language Assistance on all vital documents;

Including MST’s Notice of Language Assistance in its Rider’s Guide;

Including MST’s Notice of Language Assistance on its website;

Posting MST’s Title VI Notice of Rights, including its Notice of Language Assistance, on all MST

buses, at customer service locations, and at all public meeting locations;

Including MST’s Notice of Language Assistance on all board agendas; and

Including MST’s Notice of Language Assistance on all public-facing materials, as resources allow.

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ELEMENT 5: MONITORING AND UPDATING THE PLAN

MST will monitor its implementation of this Title VI Language Assistance Plan as follows:

MST staff will continue to track the number of language assistance calls placed to its language

interpretation service on an annual basis.

MST will survey its employees annually regarding their interaction with LEP individuals.

Whenever public hearings are noticed, MST will consider the impact the proposed fare increase;

service change, reduction, or loss; or major project will have on MST’s Safe Harbor language

populations and will provide notice in appropriate languages.

MST’s Notice of Language Assistance will be included in all notices of public meetings, including

board agendas.

Whenever public hearings or other public meetings are held, MST will review existing data on

the Safe Harbor language populations within the immediate geographic area and seek to

provide translation or interpretation services as appropriate.

MST will seek to create and maintain contact with nonprofit, social, or other groups who

support LEP populations.

MST will begin tracking its language-related expenses and will seek to implement new language

resources as the need and financial resources allow.

On a triennial basis, MST will review and update census and other LEP data and update its

Language Assistance Plan accordingly.

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